Public Sector Body Accessibility Regulations (PSBAR) require that audio and video recordings made available from September 23 2020 must meet accessibility standards, as defined by the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
When publishing video, one of the ways to make it accessible is to include captions. There are other accessibility requirements for video, in addition to captions, which are detailed in the time-based media section of WCAG.
Note that these regulations apply to pre-recorded, not live, content. PSBAR allows for up to 14 days after the video has been published, for captions to be added. Although this is minimum guidance, and your policy could be to add captions more quickly.
How accurate do captions need to be?
Government Digital Service (GDS) monitors public sector body web content for compliance with PSBAR. GDS interprets WCAG as requiring captions that accurately capture the meaning of the audio. Captions that are accurate are compliant. Captions that have not been checked and that contain mistakes are not.
WCAG success criteria 1.2.2 requires that captions are provided for all pre-recorded audio content in synchronized media, except when the media is a media alternative for text and is clearly labelled as such.
There is a failure of success criteria 1.2.2
"If the "caption" does not include all of the dialogue (either verbatim or in essence) as well as all important sounds then the 'Captions' are not real captions."
Additionally, W3C says that automatic captions are not sufficient.
"automatically-generated captions do not meet user needs or accessibility requirements, unless they are confirmed to be fully accurate. Usually they need significant editing."
Who is responsible?
The responsibility under PSBAR lies with the public sector body as a whole. In effect, this is the senior responsible officer, or the executive team. This is why leadership buy-in and a cross-organisational approach is so important when implementing accessibility.
A process like captioning, that requires time and resourcing, needs leadership and management buy-in1 to make it happen.
Ensuring that all audio and video recordings are accessible to the required standard presents challenges for institutions.
For many colleges and universities, checking and correcting for full accuracy on all video is not something they will be able to easily achieve, particularly given the volume of video being produced since the large scale move online in 2020.
Be transparent in accessibility statements
Colleges and universities have been working hard to ensure online content is accessible during an extremely challenging time. As organisations continue to improve the process of video captioning, it is important to recognise the great strides that have been made, and not to be discouraged when it may not be possible to check and edit the captions on every video produced.
Taking down video to avoid having to caption it disadvantages learners. The new learning and teaching landscape requires that students have access to the digital content they need in order to thrive. The best way forward is to be transparent about what you are doing.
Your accessibility statement is where you communicate how accessible your digital content is and what you are doing about non-compliant content.
Our guide on practical steps to meeting accessibility regulations explains how to approach statement writing.
Create department-level statements
If practice varies across your organisation, create department or school-level accessibility statements that accurately reflect the accessibility of content that staff and students will encounter.
If your school or department does not have the capacity to check and edit captions, state this under non-compliant content, or (if you are unable to provide captions due to the cost) disproportionate burden.
Is it a disproportionate burden?
The regulations provide for the situation where lack of resources will in some circumstances constrain the ability of an institution to comply fully with the accessibility requirement.
Considering the availability of built-in captioning technology for most online teaching platforms it is highly unlikely that providing captions for recorded learning sessions could be considered as an additional cost producing burden.
Captions that require substantial editing will involve a significant amount of staff resource to check and correct. This may result in a cost that your institution is unable to meet and you may decide you need to prioritise which video meets the required standard. If you do plan to claim disproportionate burden this must be done on the basis of cost. You should keep a record of your costings and decision making.
However, being unable to check and correct captions on all video should not prevent you captioning as much video as possible. Providing captions as accurately as possible remains the legal obligation.
Members of the Jisc accessibility community and HEI captioning interest group are sharing a range of approaches to meet the captioning challenge. Some have now detailed their intentions and plans.
Improving captioning of lecture content at King's
King’s College London recently approved funding to support a project to improve the captioning and transcription provision of lecture content. Co-chairs of King’s digital education accessibility task and finish group, Catherine Bone and Danielle Johnstone explain.
“Digital education accessibility and the requirement of the regulations are challenging, but we need to develop a solution focused approach as it one of King’s strategic vison 2029 guiding principles. The college has shown its commitment by approving funding for a project to improve the captioning provision of our lecture content.
The project is just part of the work we have embarked on to provide the accessible and inclusive environment we aspire to and we look forward to continuing this valuable journey.”
Aberdeen - targeting support for those who need it most
Steven Sangster, from the University of Aberdeen, describes how a robust disclosure process is essential to enable prioritised support,
“Any students who disclose and provide evidence of a disability during the application process or subsequently during their course are contacted by the disability team who can identify and implement support, which includes the requirement for quality assured captions.
The service to quality-assure captions is managed by the Centre for Academic Development. The university has a budget to outsource captions to a third party, or task captioning to subject specific student support assistants.”
As with many organisations, the team at Aberdeen currently focuses on targeting provision where it is most needed, while the team rapidly explores different approaches, with a view to scaling up. Steven tells us,
“Moving forward we are researching new captioning technologies which will allow us to comply with legislation, manage this sustainably and help ensure quality captions are available to all end users. We are considering site licenses for captioning software and specialist transcription software solutions for captioners in their role.”
Optimising audio input - tips from Jisc's accessibility community
For many recordings, automatic speech recognition (ASR) will create useful captions. Some subject specific or technical terms will present more of a challenge to the software. However, the better the automated captions, the less editing will be required.
Aiming for the best audio input you can achieve will optimise the performance of ASR, and it will be appreciated by all students who are listening to content. Here are some tips sourced from the Jisc accessibility community.
"Always use a mic. Wired is more reliable than Bluetooth."
"Do a test recording before session to check the quality."
"Having headset mics too close to your mouth picks up more speech distortion and sibilance. Try lowering or raising from mouth."
"Minimise background noise. This can be as simple as closing the door to your office."
"Use the full version of abbreviations and acronyms – this is good practice anyway, but ASR often struggles with these eg for WCAG (Web Content Accessibility Guidelines), many people say “wick-agg” which ASR cannot recognise, and it’s also unclear to newcomers to a meeting or subject what is being talked about talking about."
"Speak at a steady pace. Many students will appreciate this too eg non-native English speakers; those with language processing difficulties or difficulties with focusing. Encourage turn taking and manage behaviour like interrupting or people talking over one another."
Many organisations have decided to focus their captioning effort where it is most needed right now. This could involve a differentiating level of service.
Some criteria for deciding where to focus your captioning efforts first, or most intensively, could include:
- Courses on which a deaf or hard of hearing student is enrolled
- Content that is high usage and essential for all students
- Content that will be used for a longer period
- Courses featuring subject specific language that automated speech recognition will struggle with
If you are prioritising courses on which deaf or hard of hearing students are enrolled, it is especially important to encourage early disclosure of a support need and have a robust system for implementing adjustments.
Each lecture capture system or video platform will have a different way to generate captions, so the process for you will depend on the technology you have access to in your institution.
Join the accessibility community to discover and discuss the various captioning technologies.
A continuous and creative approach to captioning across the sector is having a transformative impact on the experiences of students.
Rachel O’Neill, senior lecturer at the University of Edinburgh, has observed an increase in positive experiences among deaf students. One deaf student she put in touch with Jisc told us,
“The engineering department has been editing the automated captions after recording their lectures so that the subtitles are correct and word for word. I have been in touch with my course mates to ask how non-deaf students have found the experience of edited subtitles. Over half of the people on my course have found them helpful.”
Positive comments from non-deaf students on the course included:
Captions are useful if the recording is not of good quality
Some people learn better through reading than listening, so subtitles are easier for learning
If a new phrase is used it is easy to understand as it is written
While the broader benefits of captioning are evident, for deaf or hard of hearing students it is essential to their learning. Feedback from a deaf student who relies on recorded lectures with corrected caption tells its own story:
“Personally, they have made so much difference. Prior to subtitles I was able to hear about 20% of the lecturers' words maximum. Now I can follow everything.”
- Captioning and subtitling for d/Deaf and hard of hearing audiences – free pdf download of comprehensive 2021 book from UCL Press
- Guidance for lecturers when working online with students who use sign language from the University of Edinburgh
- Subtitling pilot project at Moray House School of Education and Sport: review and reflections
- Strategies for inclusive online teaching practice are included in the guide we created with the National Deaf Children’s Society
- Using captions for inclusive teaching at the University of Lincoln
Thank you to Chris Heathcote from Government Digital Service for assistance with creating the guidance.
We are also grateful to contributors who have provided examples of developing practice in their organisations: Catherine Bone; Danielle Johnstone; Rachel O’Neill; Steven Sangster.
Members of the HEI Captioning Interest Group and the Jisc accessibility community have also provided valuable insights.
- 1 Accessibility: the secret to success is organisational vision and buy-in, Kellie Mote, 2020 - https://coronavirus.jiscinvolve.org/wp/2020/08/27/accessibility-the-secr...